Share Network Foundation - Page 4




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                    (e) Various others as may be                                      
                         recommended and implemented by the                           
                         organization.                                                
               On January 20, 1994, the Commissioner mailed petitioner a              
          letter seeking clarification of the information that it had                 
          provided him on and with the application.  The letter specified             
          the information that the Commissioner needed to rule on                     
          petitioner's request for exempt status and listed the name and              
          phone number of a person at the Internal Revenue Service to                 
          contact with any questions.  The letter stated:  "We can only               
          recognize you as exempt in advance of operations if you are able            
          to describe your proposed operations in sufficient detail to                
          enable us to determine that you will be organized and operated in           
          accordance with section 501(c)(3) of the Code."                             
               On April 7, 1994, the Commissioner received a response to              
          his letter.  The response, which was written by Mr. Tully, gave             
          vague answers to the questions set forth in the Commissioner's              
          letter and did not explain in detail petitioner's proposed                  
          activities or operation.                                                    
               On August 2, 1994, the Commissioner mailed petitioner                  
          another letter seeking specificity as to petitioner's                       
          organization, activities, and operation.  The letter explained              
          that the Commissioner needed specific information before he could           
          rule that petitioner was exempt from taxation under section                 






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